In October 2025, the Industrial Innovation Initiative convened its members to review and respond to the Environmental Protection Agency’s proposed rule to permanently remove program obligations for 46 source categories of the Greenhouse Gas Reporting Program (GHGRP). The Initiative has prepared and submitted the following comments to explain why our members support maintaining the current structure and reporting requirements of the GHGRP to ensure American manufacturers can collect necessary data to remain a competitive, global leader across domestic and international markets.
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